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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

v.

ALFREDO VALDES,

Defendant.

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INFORMATION

Cr.: 00 CR-331 (HB)

Filed: March 30, 2000

COUNT ONE

The United States of America, acting through its
attorneys, charges:

Conspiracy

The Relevant Parties and Entities

1. Except as otherwise noted, at all
times relevant to this Information:

a. Domecq Importers, Inc. ("Domecq Importers")
was a corporation incorporated under the laws of the State of New
York. Domecq Importers imported and distributed several brands
of alcoholic beverages, including Sauza tequila and Presidente
brandy. Domecq Importers had its headquarters in Larchmont, New
York until in or about January 1991, when it moved them to Old
Greenwich, Connecticut.

b. Before on or about May 18, 1994, Domecq
Importers was directly owned by two entities controlled by
members of the Domecq family and by a member of that family who
served as Domecq Importers' President and Chief Executive Officer
until in or about September 1995. On or about May 18, 1994,
Allied-Lyons PLC ("Allied-Lyons"), a multi-national corporation
based in England, purchased Domecq Importers and other related
companies. Later in 1994, Allied-Lyons changed its name to
Allied Domecq PLC ("Allied Domecq"). Following its acquisition
by Allied-Lyons, Domecq Importers remained a separate
corporation, which was operated as part of Allied Domecq Spirits
& Wines, the North American branch of Allied Domecq.

c. ALFREDO VALDES, the defendant, was an
employee of Domecq Importers between January 1984 and August
1996. Between 1984 and approximately 1995, VALDES held several
positions related to finance, including director of finance, vice
president for finance, and chief operating officer. In or about
1996, VALDES became the vice president responsible for marketing
all of Domecq Importers' brands.

d. ALFREDO VALDES, the defendant, was one of the
executives at Domecq Importers responsible for selecting and
contracting with wholesalers, distributors, bottlers, vendors of
advertising and display materials and services, and vendors of
other services. Along with other executives at Domecq Importers,
VALDES controlled funds that Domecq Importers had allocated for
the sale and for the marketing and promotion of its various
brands.

The Conspiracy

2. From at least as early as 1989, and
continuing up to and including in or about August
1996, in the Southern District of New York and
elsewhere, ALFREDO VALDES, the defendant, and
other persons known and unknown, unlawfully,
willfully, and knowingly did combine, conspire,
confederate, and agree together and with each
other to defraud the United States of America, and
an agency thereof, to wit, the Internal Revenue
Service ("IRS") of the United States Department of
Treasury, and to commit offenses against the
United States, to wit, to violate Sections 1341
and 1346 of Title 18, United States Code, and to
violate Section 7201 of Title 26, United States
Code.

The Objects of the Conspiracy

3. It was a part and object of the conspiracy
that ALFREDO VALDES, the defendant, and his co-conspirators, would and did defraud the
United
States and the IRS by impeding, impairing,
defeating, and obstructing the lawful functions of
the IRS in the ascertainment, evaluation,
assessment, and collection of income taxes due
from VALDES, other individuals, and various
entities by (a) impeding and impairing scrutiny by
the IRS of the true nature of payments made by
Domecq Importers to certain third parties; and (b)
impeding and impairing scrutiny by the IRS of the
true nature of payments made by certain third
parties to individuals and to numerous entities
controlled by VALDES or his co-conspirators.

4. It was a further part and object of the
conspiracy that ALFREDO VALDES, the defendant, and
his co-conspirators, would and did attempt to
evade and defeat a substantial part of the income
tax due and owing to the United States by VALDES
and others, in violation of Title 26, United
States Code, Section 7201.

5. It was a further part and object of the
conspiracy that, beginning on or about May 18,
1994, ALFREDO VALDES, the defendant, and his co-conspirators, having devised, and
intending to
devise, a scheme and artifice to (a) defraud
Allied Domecq; (b) obtain money and property from
Allied Domecq by means of false and fraudulent
pretenses, representations, and promises; and (c)
deprive Allied Domecq of its right to the honest
services of VALDES and certain Domecq Importers
executives, for the purpose of executing such
scheme and artifice, and attempting to do so,
would and did (i) place in post offices and
authorized depositories for mail matter, matters
and things to be sent and delivered by the United
States Postal Service; (ii) take and receive from
the mails such matters and things; and (iii)
knowingly cause such matters and things to be
delivered by mail according to the directions
thereon, in violation of Title 18, United States
Code, Sections 1341 and 1346.

The Means and Methods of the Conspiracy

Among the means and methods of the conspiracy were the
following:

The Tax Fraud Scheme

6. At some time prior to 1989, ALFREDO VALDES,
the defendant, met with another senior executive
of Domecq Importers. The two executives agreed to
divert money from Domecq Importers to create a
fund to provide them with additional income which
they would conceal from the IRS. They enlisted
the assistance of one or more entities that did
business with Domecq Importers, including
wholesalers, distributors, bottlers, vendors of
advertising and display materials and services,
and vendors of other services (collectively the
"outside vendors").

7. In or about 1990, ALFREDO VALDES, the
defendant, and the other senior executive referred
to in Paragraph 6 above, invited Gabriel Sagaz,
then Domecq Importers' vice president for
marketing, and Thomas Kaminsky, Domecq Importers'
vice president for sales, to join the scheme.
Sagaz and Kaminsky agreed.

8. The tax fraud scheme continued from in
or about 1989 until in or about August 1996.
In total, ALFREDO VALDES, the defendant, and
Sagaz, Kaminsky, and the other senior
executive who participated in this scheme
(the "Executive Co-conspirators") diverted
approximately $15.6 million from Domecq
Importers, and received at least an
additional $722,000 in kickbacks directly
from certain of the outside vendors, all of
which they concealed from the IRS.

Diversion of Domecq Funds ThroughFictitious Third-Party Entities

9. ALFREDO VALDES, the defendant, and the
Executive Co-conspirators employed several methods
to divert money from Domecq Importers, and to
conceal the money from the IRS. Among these
methods were the following:

a. Between at least as early as 1989 and in or
about August 1996, ALFREDO VALDES, the defendant, and the
Executive Co-conspirators arranged for certain outside vendors to
receive funds in the form of checks from Domecq Importers. At
the direction of VALDES and the Executive Co-conspirators, the
outside vendors then disbursed the funds, or a portion thereof,
by sending to VALDES checks made out to fictitious third-party
entities controlled by VALDES and the Executive Co-conspirators,
or by transferring funds by wire directly to the fictitious
third-party entities. To make these transactions appear to
relate to the legitimate business of Domecq Importers and the
outside vendors, VALDES and the Executive Co-conspirators caused
Domecq Importers and the outside vendors to issue various false
and fraudulent documents, including false purchase orders and
invoices. These documents were designed to make it appear that
the outside vendors had purchased goods and services from the
fictitious third-party entities and then resold those goods and
services to Domecq Importers. In truth and in fact, however,
neither the outside vendors nor the purported third parties
actually provided any goods or services to Domecq Importers in
relation to these transactions. The funds that the outside
vendors paid to the fictitious third-party entities were
deposited by VALDES and the Executive Co-conspirators into
offshore bank accounts. VALDES and the Executive Co-conspirators
then shared in the proceeds.

b. ALFREDO VALDES, the defendant, and the
Executive Co-conspirators also diverted money from Domecq
Importers by entering into arrangements with one or more of the
outside vendors that bottled alcoholic beverages for Domecq
Importers (the "bottlers"). Under these arrangements, VALDES and
certain of the Executive Co-conspirators instructed the bottlers
to charge Domecq Importers an additional per case "fee." The
Executive Co-conspirators then caused Domecq Importers to pay
this additional "fee" to the bottlers, and instructed the
bottlers to pay a corresponding "commission" to fictitious third-
party entities that the Executive Co-conspirators designated.
The fictitious third-party entities did not provide any goods or
services to either the bottlers or Domecq Importers. The
majority of the "commissions" generated in this manner were
deposited into offshore bank accounts controlled by the Executive
Co-conspirators.

c. ALFREDO VALDES, the defendant, and the
Executive Co-conspirators also diverted money from Domecq
Importers by causing Domecq Importers to send funds to one of its
bottlers and to one of its wholesale distributors, on the false
and fraudulent pretense that these funds would be used to promote
Domecq Importers' brands. The Executive Co-conspirators then
directed the bottler and the wholesale distributor to issue their
own checks to fictitious third-party entities that the Executive
Co-conspirators controlled. In truth and in fact, the bottler
and the wholesale distributor did not provide any promotional
services to Domecq Importers in connection with these
transactions. Moreover, VALDES and the Executive Co-Conspirators
deposited much of the "promotional" money received from the
bottler and the wholesale distributor into offshore bank accounts
they controlled.

d. ALFREDO VALDES, the defendant, certain of the
Executive Co-conspirators, and other co-conspirators who were
current or former sales representatives of Domecq Importers, also
diverted money by submitting and causing Domecq Importers to pay
invoices that they knew to be inflated or entirely fictitious.
In truth and in fact, the invoices had been submitted by entities
that were controlled by the current or former sales
representatives, who shared the money received from Domecq
Importers with VALDES and certain of the Executive Co-conspirators.

Kickbacks From Outside Vendors

10. In addition to the diversion of money
described in Paragraph 9 above, ALFREDO VALDES,
the defendant, certain of the Executive Co-conspirators, and other employees or associates of
Domecq Importers (collectively referred to as the
"Domecq Co-Conspirators") made arrangements to
receive kickbacks, in the form of money or goods
and services, directly from certain of the outside
vendors, and to conceal those kickbacks from the
IRS. Among these arrangements were the following:

a. Beginning at least as early as 1991, ALFREDO
VALDES, the defendant, and the Domecq Co-conspirators solicited
and received kickbacks from certain of the outside vendors.

b. In order to generate a substantial portion of
the funds used to pay the kickbacks, ALFREDO VALDES, the
defendant, and the Domecq Co-conspirators arranged for Domecq
Importers to award contracts to certain of the outside vendors,
who then submitted numerous false and fraudulent invoices to
Domecq Importers. These invoices either (a) reflected
transactions that were entirely fictitious; (b) sought payment
for substantially more goods or services than the outside vendor
had actually produced for Domecq Importers; or (c) sought payment
for goods or services that were priced higher than the outside
vendor otherwise would have charged. VALDES and the Domecq
Co-conspirators then approved these invoices for payment and Domecq
Importers paid them. After the invoices were paid, the outside
vendors used the funds generated through these invoices to make
payments to VALDES and the Domecq Co-conspirators, either
directly or to a fictitious third-party entity named "Fortraco
Intl.," which was simply an alias for VALDES and certain of the
Domecq Co-conspirators.

Tax Consequences of the Fraud

11. Through the creation of fraudulent, inflated,
and fictitious invoices, and the use of offshore
bank accounts, ALFREDO VALDES, the defendant, and
his co-conspirators impeded and impaired the IRS's
scrutiny of (a) the U.S. Individual Income Tax
Returns, Forms 1040, filed by VALDES and the
Executive Co-conspirators, as well as the U.S.
Corporate Tax Returns, Forms 1120, filed by Domecq
Importers; (b) the true nature of payments made by
Domecq Importers to certain third parties; and (c)
the true nature of payments made by certain third
parties to individuals and a variety of entities
controlled by VALDES or his co-conspirators.
Moreover, VALDES did not report his receipt of any
portion of the money diverted from Domecq
Importers or the kickbacks on his and his spouse's
U.S. Individual Income Tax Returns, and the
Executive Co-conspirators did not report their
receipt of most, if not all, of the money diverted
from Domecq Importers and the kickbacks on their
U.S. Individual Income Tax Returns. As a result,
those tax returns substantially underreported the
taxable income and the correct amount of tax due
and owing from these individuals.

The Scheme to Defraud Allied Domecq

12. Initially, the diversion of funds from Domecq
Importers by ALFREDO VALDES, the defendant, and
the Executive Co-conspirators, described in
Paragraph Nine above, was carried out with the
knowledge and approval of at least one co-owner of
Domecq Importers, as well as one or more senior
executives within the worldwide Domecq
organization. However, from on or about May 18,
1994, when Allied-Lyons acquired Domecq Importers,
the diversion of funds by VALDES and his co-conspirators, described in Paragraph Nine above,
was done without the knowledge and consent of the
public shareholders of Allied Domecq or the
majority of the Board of Directors of Allied
Domecq, although the diversion of funds was known
and approved by at least one member of the Board.
Moreover, from on or about May 18, 1994, the
kickback scheme, described in Paragraph Ten above,
was carried out without the knowledge and consent
of the public shareholders or the Board of
Directors of Allied Domecq.

13. The mails were used in several ways to
further the above-described schemes. For
example, the mails were used in connection
with the diversion of funds from Domecq
Importers in that fraudulent purchase orders
issued by Domecq Importers to the outside
vendors and fraudulent invoices issued by the
outside vendors to Domecq Importers were sent
through the mails. Similarly, many of the
outside vendors who participated in the
kickback scheme regularly mailed fraudulent
invoices to Domecq Importers to request
payment for goods and services. Moreover,
Domecq Importers regularly mailed checks to
the outside vendors in payment of the
fraudulent invoices.

Concealment of the Schemes

14. Among other things, in or about August 1996,
ALFREDO VALDES, the defendant, in order to conceal
the scheme, burned certain files and bank records,
which were personally incriminating and which he
understood were responsive to a grand jury
subpoena ducestecum dated August 4, 1996, that
had been served on representatives of Domecq
Importers.

Overt Acts

15. In furtherance of the conspiracy and to
effect its objects, ALFREDO VALDES, the defendant,
and his co-conspirators committed the following
overt acts, among others, in the Southern District
of New York and elsewhere:

a. On or about December 28, 1993, ALFREDO
VALDES, the defendant, received from an outside vendor located in
the Southern District of New York a check made payable to "The
Winston Group" in the amount of $44,550.

b. On or about April 15, 1994, ALFREDO VALDES,
the defendant, and his spouse filed a U.S. Individual Income Tax
Return, Form 1040, for the calendar year 1993, which failed to
report all of his 1993 income from the schemes described in this
Count, and thereby substantially underreported the correct tax
due and owing.

c. On or about January 4, 1994, ALFREDO VALDES,
the defendant, received from an outside vendor located in the
Southern District of New York a check made payable to "The
Winston Group" in the amount of $129,600.

d. On or about April 15, 1995, ALFREDO VALDES,
the defendant, and his spouse filed a U.S. Individual Income Tax
Return, Form 1040, for the calendar year 1994, which failed to
report all of his 1994 income from the schemes described in this
Count, and thereby substantially underreported the correct tax
due and owing.

e. On or about February 18, 1995 an outside
vendor issued a check to "Grupo Veracruz" in the amount of
$143,325.

f. On or about July 31, 1996, an outside vendor
located in the Southern District of New York issued a check to
"Baja Sur Props" in the amount of $119,126.

(Title 18, United States Code, Section 371.)

COUNT TWO

The United States of America, acting through its
attorneys, further charges:

The Money Laundering Conspiracy

16. From on or about May 18, 1994, up to and
including in or about August 1996, in the Southern
District of New York and elsewhere, ALFREDO
VALDES, the defendant, and others known and
unknown, unlawfully, willfully, and knowingly did
combine, conspire, confederate, and agree together
and with each other to commit an offense against
the United States, to wit, to violate Section 1956
of Title 18, United States Code.

17. It was a part and object of the conspiracy
that ALFREDO VALDES, the defendant, and his
co-conspirators, in an offense involving and
affecting interstate and foreign commerce,
knowing that the property involved in certain
financial transactions represented the
proceeds of some form of unlawful activity,
unlawfully, willfully, and knowingly would
and did conduct and attempt to conduct such
financial transactions which in fact involved
the proceeds of specified unlawful activity,
to wit, the mail fraud scheme to defraud
Allied Domecq involving the diversion of
corporate funds from Domecq Importers and the
receipt of kickbacks from outside vendors, as
described in Paragraphs Twelve through
Fourteen of Count One of this Information,
with intent to engage in conduct constituting
a violation of Sections 7201 and 7206(1) of
the Internal Revenue Code of 1986, in
violation of Section 1956(a)(1)(A)(ii) of
Title 18, United States Code, and knowing
that the transactions were designed in whole
and in part to conceal and disguise the
nature, location, source, ownership, and
control of the proceeds of some form of
unlawful activity, in violation of Section
1956(a)(1)(B)(i) of Title 18, United States
Code.

Means and Methods of the Money Laundering
Conspiracy

18. Paragraph One and Paragraphs Six
through Fourteen of Count One of
this Information are reincorporated
and realleged as if fully set forth
herein.

19. ALFREDO VALDES, the defendant, received some of
the diverted corporate funds from the outside
vendors in the form of checks or wire transfers
made payable to one of the fictitious third-party
entities controlled by ALFREDO VALDES, the
defendant, and the Executive Co-conspirators. The
payments by the outside vendors were made to
accounts in the name of the Winston Group, Grupo
VeraCruz ("VeraCruz"), Premier Maldonado
("Maldonado"), Baja Sur, and Fortraco
International ("Fortraco"). Each of these
fictitious third-party entities maintained an
offshore bank account. The Winston Group
maintained account number 752500 at the First
National Bank of Aruba (the "Winston Group
Account"). Fortraco maintained account number
371050 at the First National Bank of Aruba (the
"Fortraco Account"). VeraCruz and its successor
Maldonado maintained account number 797021 at the
First National Bank of Aruba (the "VeraCruz
Account"). Baja Sur maintained account number
797022 at the First National Bank of Aruba (the
"Baja Sur Account").

20. In the course of the fraud scheme outlined in
Count One, the outside vendors mailed many of their checks to
ALFREDO VALDES, the defendant, who in turn sent the checks to the
First National Bank of Aruba. There, bank officers who were
designated agents of the fictitious third-party entities endorsed
the checks and deposited them into the relevant accounts. At
various times, ALFREDO VALDES, the defendant, withdrew monies
from these accounts for his own use and for distribution among
the Executive Co-Conspirators. To this end, the monies were
usually transferred into other offshore accounts controlled by
the defendant or by the Executive Co-Conspirators.

21. With respect to the kickback payments made by the
outside vendors, referred to in Paragraph Ten above, ALFREDO
VALDES, the defendant, received some of these payments in the
form of checks made payable to an entity named "Fortraco Intl."
VALDES and a co-conspirator controlled this entity and maintained
a bank account for this entity in a domestic bank.

Overt Acts

22. In furtherance of the conspiracy and to effect the
illegal objects thereof, ALFREDO VALDES, the defendant, and
others known and unknown to the United States, committed the
following overt acts, among others, in the Southern District of
New York and elsewhere:

a. On or about May 24, 1994, ALFREDO VALDES, the
defendant, withdrew $149,000 from the Winston Group Account,
which funds were distributed to one or more of the Executive Co-conspirators.

b. On or about June 6, 1994, ALFREDO VALDES, the
defendant, deposited into the Fortraco Account a check in the
amount of $208,300, which check had originally been mailed from
New York, New York.

c. On or about June 13, 1994, ALFREDO VALDES, the
defendant, deposited into the Winston Group Account a check in
the amount of $200,760.

d. On or about June 28, 1994, ALFREDO VALDES, the
defendant, deposited into the Fortraco Account a check in the
amount of $200,000.

e. On or about June 28, 1994, ALFREDO VALDES, the
defendant, deposited into the Fortraco Account a check in the
amount of $68,720.

f. On or about June 28, 1994, ALFREDO VALDES, the
defendant, withdrew $200,000 from the Winston Group Account,
which funds were distributed to one or more of the Executive Co-conspirators.

g. On or about June 28, 1994, ALFREDO VALDES, the
defendant, withdrew $200,000 from the Fortraco Account, which
funds were distributed to one or more of the Executive Co-conspirators.

h. On or about July 13, 1994, ALFREDO VALDES, the
defendant, withdrew $270,000 from the Fortraco Account, which
funds were distributed to one or more of the Executive Co-conspirators.

i. On or about August 29, 1994, ALFREDO VALDES,
the defendant, deposited into the Winston Group Account a check
in the amount of $102,600, which check had originally been mailed
from New York, New York.

j. On or about September 12, 1994, ALFREDO
VALDES, the defendant, arranged for the wire transfer of $122,800
into the Winston Group Account.

k. On or about September 15, 1994, ALFREDO
VALDES, the defendant, withdrew $220,000 from the Winston Group
Account, which funds were distributed to one or more of the
Executive Co-conspirators.

l. On or about September 22, 1994, ALFREDO
VALDES, the defendant, deposited into the Veracruz Account a
check in the amount of $41,200.

m. On or about September 23, 1994, ALFREDO
VALDES, the defendant, deposited into the Fortraco Account a
check in the amount of $61,653.

n. On or about September 23, 1994, ALFREDO
VALDES, the defendant, deposited into the Fortraco Account a
check in the amount of $220,000.

o. On or about October 13, 1994, ALFREDO VALDES,
the defendant, withdrew $275,000 from the Fortraco Account, which
funds were distributed to one or more of the Executive Co-conspirators.

p. On or about October 14, 1994, ALFREDO VALDES,
the defendant, deposited into the Winston Group Account a check
in the amount of $173,355.10, which check had originally been
mailed from New York, New York.

q. On or about October 28, 1994, ALFREDO VALDES,
the defendant, withdrew $170,000 from the Winston Group Account,
which funds were distributed to one or more of the Executive Co-conspirators.

r. On or about December 16, 1994, ALFREDO VALDES,
the defendant, deposited into the Veracruz Account a check in the
amount of $19,500.

s. On or about December 18, 1994, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $250,000.

t. On or about December 18, 1994, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $66,096.

u. On or about January 6, 1995, ALFREDO VALDES,
the defendant, withdrew $310,000 from the Fortraco Account, which
funds were distributed to one or more of the Executive Co-conspirators.

v. On or about March 2, 1995, ALFREDO VALDES, the
defendant, withdrew $4500 from the Fortraco Account, which funds
were distributed to one or more of the Executive Co-conspirators.

w. On or about March 7, 1995, ALFREDO VALDES, the
defendant, deposited into the VeraCruz Account a check in the
amount of $143,325.

x. On or about April 5, 1995, ALFREDO VALDES, the
defendant, deposited into the Fortraco Account a check in the
amount of $323,700.

y. On or about April 18, 1995, ALFREDO VALDES,
the defendant, deposited into the Veracruz Account a check in the
amount of $42,300.

z. On or about April 21, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $210,000.

aa. On or about April 21, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $92,364.

bb. On or about April 25, 1995, ALFREDO VALDES,
the defendant, withdrew $210,000 from the Fortraco Account, which
funds were distributed to one or more of the Executive Co-conspirators.

cc. On or about May 4, 1995, ALFREDO VALDES, the
defendant, withdrew $290,000 from the Fortraco Account, which
funds were distributed to one or more of the Executive Co-conspirators.

dd. On or about July 20, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $54,560.

ee. On or about July 24, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $150,000.

ff. On or about July 24, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $73,978.

gg. On or about August 29, 1995, ALFREDO VALDES,
the defendant, deposited into the VeraCruz Account a check in the
amount of $288,997.50, which check had originally been mailed
from New York, New York.

hh. On or about September 13, 1995, ALFREDO
VALDES, the defendant, withdrew $285,000 from the VeraCruz
Account, which funds were distributed to one or more of the
Executive Co-conspirators.

ii. On or about October 11, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $240,000.

jj. On or about October 11, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $82,249.

kk. On or about December 6, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $40,047.50.

ll. On or about December 7, 1995, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $20,000.

mm. On or about December 18, 1995, ALFREDO
VALDES, the defendant, deposited into the Fortraco Account a
check in the amount of $54,720.

nn. On or about December 28, 1995, ALFREDO
VALDES, the defendant, deposited into the Fortraco Account a
check in the amount of $9,767.50.

oo. On or about December 29, 1995, ALFREDO
VALDES, the defendant, deposited into the Fortraco Account a
check in the amount of $55,597.

pp. On or about January 7, 1996, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $54,778.80.

qq. On or about January 16, 1996, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $5,000.

rr. On or about February 28, 1996, ALFREDO
VALDES, the defendant, deposited into the Fortraco Account a
check in the amount of $39,000.

ss. On or about March 6, 1996, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $62,100.

tt. On or about April 8, 1996, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $55,192.

uu. On or about April 16, 1996, ALFREDO VALDES,
the defendant, deposited into the Fortraco Account a check in the
amount of $86,655.70.

vv. On or about July 31, 1996, ALFREDO VALDES,
the defendant, deposited into the Baja Sur Account a check in the
amount of $119,126.